WASHINGTON --- Giving regulators an overview of the bank's accomplishments and compliance goals is the most important thing an institution can do to produce a positive exam.
Cheryl G. Petty, assistant director in the central region of the Office of Thift Supervision, said such overviews give examiners a starting point and steer them to the good things going on at the bank.
"You have to show and tell us what you're doing," Ms. Petty said last week at the Savings and Community Bankers of America's national compliance conference.
While examiners' latest emphasis has been on fair lending to minorities, the next area regulators are likely to go after is sexual bias, said Francis X. Grady, with the Cleveland law firm of Grady & Monroe. Examiners may start looking more closely at loan denials to single women, Mr. Grady said.
"Women are a protected class under the Equal Credit Opportunity Act," he reminds the audience.
Banks ought to appoint a coordinator to act as a liaison between examiners and senior managers, she said. That person should be responsible for finding missing information and tying up loose ends.
Creating, an examination file also makes an exam go more smoothly, Ms. Petty said. The file should contain all self-assessments, results of geocoding, and other data that demonstrate a bank's compliance.
Mr. Grady added that banks compile a three-ring binder of written policies that examiners can easily look through. Regulators look especially closely at banks' training programs, be said. "The quality of training differentiates adequate compliance from good compliance," Mr. Grady said.
Banks should plan to analyze one or two major compliance areas monthly; for example, Truth-in-Lending in January, Community Reinvestment Act in February, and Bank Secrecy Act in March, he said.